CMS Cancels MIPS Facility-Based Scoring Option for Performance Year (PY) 2022

The Centers for Medicare & Medicaid Services (CMS) announced, in response to the ongoing COVID-19 public health emergency (PHE), a measure suppression policy in the Fiscal Year (FY) 2023 Hospital Value-Based Purchasing (VBP) Program. This policy allows CMS to suppress the use of measure data if the agency determines that circumstances caused by the COVID-19 PHE significantly affected those measures and the resulting quality scores. CMS finalized this special scoring policy for FY 2023, resulting in a total performance score not being calculated for any hospital for FY 2023.

This finalized policy directly impacts the Merit-based Incentive Payment System (MIPS) facility-based scoring in performance year 2022. CMS uses the total performance score from the Hospital VBP Program to calculate the previous year's MIPS facility-based scores. Since the 2023 total performance score from the Hospital VBP will not be available, the MIPS facility-based score will not be able to be calculated for PY 2022.

While this may have little to no impact on most anesthesia groups reporting to MIPS, there may be some groups that rely on the facility-based score to satisfy their reporting requirements and will be directly affected by this policy. Eligible clinicians and groups that rely on the facility-based score will need to submit data on MIPS quality measures to receive a score other than zero for the quality performance category. CMS will automatically calculate a score for the cost performance category for facility-based clinicians and groups that meet the case minimum. If the facility-based clinicians or group does not meet the case minimum for any cost measures, the cost performance category will be reweighted to 0% and the weight redistributed to other performance categories. Facility-based clinicians and groups that find themselves without available or applicable measures to report can request a performance category reweighting by submitting an extreme and uncontrollable circumstances (EUC) application.

For additional information on this announcement from CMS, please visit the Quality Payment Program website. For more information on how this could impact you or your group, refer to the 2022 Facility-Based Quick Start Guide.

Please contact the Anesthesia Quality Institute at [email protected] or the ASA Department of Quality and Regulatory Affairs at [email protected] with any further questions.